Vendor Access Program
Research shows that certain health care vendor activities allowed under the Political Reform Act, such as accepting gifts from vendors, may affect provider behavior and give the appearance of favoritism. To address this issue, the UC Health Care Vendor Relations policy provides system-wide standards aimed at reducing the potential for industry influence on health care providers’ decisions.
Proper vendor credentialing helps UC Davis Health ensure a safe patient and work environment and provides the necessary controls to uphold our values of integrity in every situation. Vendors and the individuals representing them (Representatives) must understand and uphold University policies and standards.
Representatives entering any of the UC Davis Health facilities must:
- Register with SEC3URE (also known as Reptrax),
- Complete all credentialing requirements,
- Comply with the Vendor Access Program rules,
- Maintain up-to-date credentials in Reptrax, and
- Wear the Reptrax issued badge so that is clearly visible to all staff and other visitors.
Representatives who fail to maintain appropriate credentials and/or comply with UC Davis Health policies or legal/regulatory requirements are subject to reprimand, up to and including termination of visiting privileges.
If you have any questions related to vendor compliance or conflicts of interest, please contact the UC Davis Health Compliance Department directly (https://health.ucdavis.edu/compliance/contact/).
A list of frequently asked questions (FAQs) regarding vendor compliance can be found below.
Do ALL Vendor Representatives have to register in Reptrax?
All individuals who represent a company doing business with or seeking to do business with UC Davis Health must register in Reptrax. The following representatives are excluded from Reptrax registration:
- Clinical Engineering Representatives (Contact the Clinical Engineering Office)
- Building Contractor Representatives (Contact Facilities Design and Construction for more information)
- Third-Party Payer Representatives (Auditors)
- Clinical Trial Monitors
- Delivery Services (i.e. FexEx, Amazon, Pizza Hut)
- Representatives with a UC Davis Health printed badge
Do ALL vendors have to sign the confidentiality agreement?
Generally, any Representative with access to patient care areas must sign a confidentiality agreement, but the following may be acceptable in lieu of a confidentiality agreement:
- A HIPAA Business Associate Agreement,
- A determination by the Compliance Department that the vendor is acting as a member of a covered entity (as defined by HIPAA), or
- Provisions to ensure that the vendor does not have access to protected health information.
For additional information or questions about the confidentiality standards, contact the UC Davis Health Compliance Department at (916) 734-8808 or email@example.com.
Can vendors use University resources like the copier or the fax machine?
In general, a Representative may not utilize University resources, especially for a commercial purpose.
Can vendors leave gifts for the staff when they visit?
No. Representatives may not provide gifts or giveaways of any nature (pens, note pads, coffee/coffee mugs, gift cards, etc.) to UC Davis Health workforce members during their visit. For additional information about our gift and conflict of interest (COI) policies, visit the Compliance COI webpage.
Can the department solicit vendors for donations? Does it need to be approved?
UC and UC Davis policy allow for University departments to solicit vendors for unrestricted donations so long as (1) there are no company promotional materials at the event, (2) the appropriate University departments are notified and approve of the event, (3) the vendor does not provide the donation directly to any individual.
An unrestricted donation is one that doesn’t have any “strings attached” and where the department has full autonomy to decide how it will be used. For example, the vendor cannot present at the supported event or require that the donation is used for a particular activity.
The department may decide to use a vendor’s donation to purchase food for an event or fund an employee’s travel expenses, but these items must be purchased/reimbursed directly by the department and not the vendor. Additionally, the vendor cannot have any involvement in the selection of the individual recipients (i.e. the training participant or a conference attendee).
Funds donated to support educational activities must be managed in accordance with conflict-of-interest standards set by the relevant national governing body or by ACCME if no governing body exists. Departments must notify the learners of the vendor’s support, but cannot imply that the vendor has “sponsored” the activity. For example, the department can say, “This activity is supported in part by a donation from [name of vendor]”, but cannot say the activity is “sponsored” by the vendor.
Any donation to the department must be approved by department leadership and may require additional approval in accordance with PPM 260-15. For additional information about accepting donations, please contact the UC Davis Health Sciences Development and Alumni Relations department.
Can the department provide vendor-donated giveaways to the patients and employees who attend a University event?
Patient Attendees: Generally, nominal vendor-donated giveaways (i.e. $10 gift cards) can be provided to patients so long as the intent is not to encourage or entice them to seek care, purchase items or services or to select a particular provider. Please contact Compliance or Legal Affairs if you have questions about providing giveaways to patients.
Employee Attendees: While distribution of vendor-donated prizes and awards to employees is not explicitly addressed in University policy, giving gifts and prizes to employees using University funds is allowed and the value should be limited to avoid tax implications in accordance with UCOP BFB-G-41 and UC Davis PPM 380-50.
Please note that donations cannot be accepted if they are provided as promotional items or with the intent of directing business to the vendor. We recommend that all giveaways valued at more than $25 are first reviewed by Compliance.
The vendor is disrupting our services and not following our department rules. Can I ask them to leave?
Yes. Representatives are allowed to visit UC Davis Health at the request and invitation of our personnel only. Departments can revoke that invitation at any time and ask them to leave if the Representative is not following the unit’s policies or is disrupting business operations. Furthermore, departments may implement additional rules for vendor on-site visits that exceed University standards in order to meet the individual needs of each location. Representatives who fail to comply with University/department policies or legal/regulatory requirements are subject to reprimand, up to and including termination of visiting privileges. If you or your department is having issues with a vendor or you have had to ask a vendor to leave your department, please contact the UC Davis Health Compliance Department at (916) 734-8808 or firstname.lastname@example.org.
Remember, the presentation of products and services by a Vendor Representative at UC Davis Health is a privilege, not a right.
I’d like to educate my staff about vendor compliance, do you have any handouts I can use?
What if I have non-compliance related questions about the Vendor Access Program?
The UC Davis Health Vendor Access Program is managed and maintained by the Supply Chain Management team. For more information about the program activities and questions about vendor visits, contact their office at (916) 734-2475 or via their website https://health.ucdavis.edu/supplychain/.
UC Davis Health Reptrax Training Presentation (Coming Soon!)